Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
chapter
Virginia Stormwater Management Program (VSMP) Regulation (formerly 4VAC50-60) [9 VAC 25 ‑ 870]
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1/24/09  11:12 am
Commenter: Jeff Walker, resident Northampton County

Support for petition #68
 

 
Dear Mr. Weeks,
      Members of the agricultural community on the Eastern Shore are quite familiar with the drainage/ water runoff from large scale agricultural operations. My comments are directed specifically to the production of tomatoes grown under plasti-culture operations. Conventional agricultural operations,(non plasti-culture), practiced by other farmers, do a reasonably good job of controlling run-off as it relates to their farming practices.
       In plasti-culture farming, run-off of rain water is significantly higher because of soil compaction by use of heavy equipment, minimal soil cultivation, and the use of plastic to cover approximately one third of the field surface. It is realistic to expect this, and I recognize the right of operators to drain their fields as crops will not survive in standing water or extended periods of wet soils. Drainage of these fields is accomplished by ditching either by mechanical or manual means through grass buffers and into transport ditches.  These ditches, both public and private, convey this run-off water into the tidal creeks and marshes of the Eastern Shore.  Fertilizer and pesticide contents in this run-off are a matter of scientific study, much of  which has been accomplished. What is undeniable is the large amount of sediment in this run off which is slowly but surely filling the marshes and creeks into which they empty.  I believe, as does the general public and hopefully DEQ, that no one or entity has the right to deliberately direct the above described run-off into the creeks and marshes of the Commonwealth of Virginia.  Most long-time Eastern Shore residents have observed a gradual but steady shallowing of  our tidal waters over the years. Plasti-culture operations are unquestionably expediting this process.
       The question is: What is the solution to this problem? Eliminating plasti-culture operations on the Eastern Shore is not an option I advocate or support. It is an important part of our local economy, providing many jobs and revenues for local businesses.  It has become apparent, with a few exceptions, that plasti-culture operators are not going to cooperate voluntarily. (It should be noted that more than one land owner has not renewed leases with these operators because of run off problems).  I oppose the digging of ditches through grass buffer strips, while recognizing the right and necessity to drain fields.
        Solution: Directing run-off through existing, non-ditched grass buffers is an efficient and cost effective sediment control method.  Most plasti-culture operations have large ponds which meet their irrigation needs. ALL RUN-OFF should be directed to these or newly dug ponds which will serve a dual purpose, i.e. sediment control and a source of irrigation water. It might also minimize or eliminate the need for pumping irrigation water from the aquifers. These newly dug ponds should be of sufficient size to handle large amounts of run-off.
        In closing, I strongly support DEQ Petition #68, the "Prevention of Degradation of Water Quality on the Eastern Shore as a Result of Large Scale Agricultural Operations". (As noted, my comments are directed specifically to plasti-culture (tomato production) operations).
        I request an e-mail acknowledgement of receipt of this letter.                                                                                                                                                                                                                                        Sincerely,
                                                                                                                                                              Jeff Walker
CommentID: 6762